DOJ-OGR-00021025.jpg
655 KB
Extraction Summary
7
People
2
Organizations
1
Locations
2
Events
5
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
655 KB
Summary
This legal document is a page from a court filing arguing against a defendant's claim of prejudice due to the death of potential witnesses. The prosecution contends that the defendant's assertions about what these witnesses (architects and a housekeeper) would have testified are speculative and unsubstantiated. It further argues that other witnesses, such as Juan Alessi, Larry Visoski, and David Rodgers, were available and did testify about similar matters, like renovations at Epstein's residences, meaning the information was obtainable through other means.
People (7)
| Name | Role | Context |
|---|---|---|
| Epstein |
Mentioned throughout as the individual whose residences, renovations, and private airplane are subjects of testimony.
|
|
| Defendant | Defendant |
The subject of the legal filing, who is arguing that the absence of deceased witnesses prejudiced her case. The docum...
|
| Juan Alessi | Witness |
Mentioned as a witness who testified at trial about working for Epstein.
|
| Larry Visoski | Witness |
Mentioned as a witness who testified at trial about working for Epstein.
|
| David Rodgers | Witness |
Mentioned as a witness who testified at trial about working for Epstein.
|
| King |
Named in the case citation 'United States v. King, 560 F.2d 122, 130 (2d Cir. 1977)'.
|
|
| Long |
Named in the case citation 'United States v. Long, 697 F. Supp. 651, 657 (S.D.N.Y. 1988)'.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States | government agency |
Party in the legal cases 'United States v. King' and 'United States v. Long'.
|
| DOJ-OGR | government agency |
Appears in the footer of the document (DOJ-OGR-00021025), likely a Department of Justice identifier.
|
Timeline (2 events)
A trial occurred where witnesses like Juan Alessi, Larry Visoski, and David Rodgers testified.
The Defendant claims two architect witnesses and a live-in housekeeper, who could have provided testimony, have died.
two architect witnesses
live-in housekeeper
Locations (1)
| Location | Context |
|---|---|
|
Location of Epstein's townhouse where the Defendant allegedly spent limited time.
|
Relationships (5)
The document states the Defendant claims she 'spent only limited time with Epstein at his townhouse in New York'.
The document states Juan Alessi was one of the individuals Epstein employed to work at his residences.
The document states Larry Visoski was one of the individuals Epstein employed to work at his residences.
The document states David Rodgers was one of the individuals Epstein employed to work at his residences.
The document refers to 'Epstein’s live-in housekeeper'.
Key Quotes (2)
"could have established"Source
— Defendant
(The Defendant's claim about what two deceased architect witnesses could have done regarding the timeline for Epstein's renovations.)
DOJ-OGR-00021025.jpg
Quote #1
"no way of knowing what [an absent witness’s] testimony would have been"Source
— United States v. Long, 697 F. Supp. 651, 657 (S.D.N.Y. 1988)
(A legal precedent cited to argue that there is no prejudice from an absent witness when their potential testimony is unknown.)
DOJ-OGR-00021025.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,239 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page199 of 221
A-399
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 42 of 45
A-399
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 42 of 45
defense witnesses died three years or more prior to indictment); United States v. King, 560 F.2d 122, 130 (2d Cir. 1977) (defense witness died a year prior to the indictment). Here, the Defendant largely speculates about the contents of these deceased witnesses’ absent testimony. She states, for example, that the two architect witnesses “could have established” the timeline for Epstein’s residences and renovations at each but does not say what that timeline is. Maxwell Br. at 29. Similarly, the Defendant states that Epstein’s live-in housekeeper could have testified that the Defendant spent only limited time with Epstein at his townhouse in New York but provides little basis or detail for that anticipated testimony. As with the documentary evidence above, such speculation, with the apparent presumption that absent evidence would necessarily favor the Defendant, is insufficient to establish actual prejudice. See United States v. Long, 697 F. Supp. 651, 657 (S.D.N.Y. 1988) (no prejudice where there is “no way of knowing what [an absent witness’s] testimony would have been”).
Second, the Defendant fails to establish that the content of these witnesses’ testimony could not have been introduced into trial by other means. At trial, witnesses testified that Epstein employed a significant number of individuals to work at his residences, renovate those residences, or fly his private airplane. Some, like Juan Alessi, Larry Visoski, and David Rodgers, testified at trial. Still others were listed on the parties’ witness lists. The Defendant does not explain why these witnesses’ testimony, or the testimony of those listed witnesses who were not called, could not have supplied the same information that she seeks from individuals who were unavailable to testify. Her assertion that only individuals that have since died could provide adequate testimony is entirely unsubstantiated. Similarly, the Defendant does not explain why evidence of construction or renovations at Epstein’s residences could not be proven by other witness testimony or by documentary evidence.
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DOJ-OGR-00021025
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